WCS has reached a milestone in the application process to become licensed to construct and operate a consolidated interim storage facility for spent nuclear fuel (SNF). Last week we submitted the final revisions to our application to the Nuclear Regulatory Commission (NRC), concluding our responses to the NRC’s Requests for Supplemental Information (RSIs).
The NRC was timely in issuing the RSIs and in setting public discussions with us about the supplemental information they needed. That underscores the serious consideration the NRC is giving our application.
We submitted the initial application on April 28, 2016, so it is not quite 1-year into the 3-year application process, and we are making real progress. While it is important that the application process have a thoughtful and careful review, it is also essential that we keep our nose to the grindstone and be vigilant about attaining at least a partial solution to our country’s nuclear waste management dilemma that grows more costly for taxpayers each year.
So it is encouraging that the NRC is also keeping the process on a timely track. They are in the middle of determining the scope of the Environmental Impact Statement and just recently extended the public comment period until April 28, 2017. There will also be a fourth public meeting on April 6.
Transportation of SNF Raises Questions& Discovers Enormous Planning Effort Underway
It came to our attention at the recent public hearings in February that, in addition to some genuine concern about the safe transportation of spent nuclear fuel (SNF), there is some confusion about the security surrounding the transportation of SNF. So, just to be clear, the U.S. Department of Energy (DOE) will take title to the spent fuel and will join with the U.S. Department of Transportation (DOT) to ensure that the SNF is transported safely and according to DOT and NRC regulations.
The security plans that are coordinated with state and local law enforcement and first responders in the states and communities along a route (once one is determined) are the responsibility of DOE and DOT in conjunction with the Department of Homeland Security. In addition to overseeing the safety and security of SNF shipments, the DOT is responsible for regulating the safety of all hazardous material shipments, that’s about 300 million packages a year.
The DOE National Transportation Stakeholders Forum (NTSF) is the mechanism through which DOE communicates at a national level with states and tribes about the Department’s proposed shipments of SNF and radioactive waste and materials, as well as occasional high-visibility shipments that are nonradioactive. [Read the NTSF Charter here.]
All states along major rail routes are active participants in the NTSF.
The NTSF has subcommittees that are currently addressing protocols for the funding of emergency response preparations under Section 180(c) of the Nuclear Waste Policy Act (NWPA), the development of rail routes through the various states, and on developing protocols for inspecting rail shipments. DOE also has an effort to inspect short rail lines in the vicinity of nuclear power plants that will be used to transport materials away from the sites.
The DOT’s Federal Railway Administration (FRA) is responsible for regulating the overall safety of rail shipments. As part of FRA’s oversight, the FRA has delegated authority to the States for the inspection of rail shipments of hazardous materials, including SNF.
The NTSF is currently assessing which states have qualified inspection programs, and how states can coordinate SNF inspections for rail shipments passing through multiple jurisdictions.
With an understanding of all the federal and state coordination that is underway, I am confident that both DOE and DOT will have an approved SNF transportation plan, along with the necessary equipment and infrastructure, well in advance of the first shipment to a Consolidated Interim Storage Facility. We certainly will not open for operation until all the required elements are in place.
As an example of the degree of coordination and planning required for the rail shipment of SNF, the Midwest Council of State Governments has recently published their “Planning Guide for Shipments of Radioactive Material through the Midwestern States” in February 2017. Other updated state and regional guidance and planning will soon follow.
Considering the fact that there have been some 7,000 shipments of SNF over millions of miles on land and by sea worldwide since 1971, and while there have been occasional accidents, there has never been an accident in which a container with highly radioactive material has been breached.
That is an impressive safety record and while I have touted it before in my blogs, it cannot be overstated.
So, while the robust public discussion about transportation is important —and I certainly relish the opportunity to provide the data that supports the fact that transporting SNF is safe — it should not be the only conversation.
It’s been five years since the Blue Ribbon Commission on America’s Nuclear Future presented its report to DOE in January of 2012 recommending the consolidation of spent nuclear fuel at an interim storage facility. Those recommendations are still valid and the need for a solution grows more urgent with the passage of time.
We need to keep moving forward.